We have built a leading edge practice in the area of health care analytics. Our team of analysts are trained in both insurance and financial disciplines with expertise in statistics, underwriting, and data visualization. Our leadership in the area of analytics is evidenced by our early adoption (over five years ago) of a claim analytics software platform called NavMD. As a client you will have access to capabilities that include…
- Premium rate calculations
- Initial and ongoing claims reserve calculations
- Annual funding projections
- Monthly claim reporting, including stop loss settlement
- Forecasting of costs
- Dashboard/executive level reports
- Risk analysis modeling
- Claims analysis by chronic conditions, episodes of care, severity, comorbidities, frequency, and medical compliance
- Board-level reports and presentations
We are constantly developing tools to help uncover meaningful information in a health care industry that continues to fight the call for transparency. With our services, much of the health care cost mystery can be removed and a path to better decision making can be followed. Our data services serve a critical link to wellness initiatives as we have the ability to provide meaningful metrics that will satisfy C-Suite executives, Board Members, and operational managers.
We offer a portfolio of resources to assist clients navigate the complexities of employee benefits regulatory compliance. The Fedeli Group has internal subject matter experts but also relies on strategic relationships with preferred law firms, CPA firms, industry contacts, and technology software tools to maximize compliance while minimizing the time commitment on your internal staff.
A service we provide for clients is a regulatory review designed to examine common components of a Department of Labor (DOL) audit. From this review, we identify areas of concern, deficiencies, while also verifying areas that meet regulatory standards. When appropriate, we recommend corrective action and assist you in find an appropriate solution. Areas of review include…
The Department of Labor views the Summary Plan Description (SPD) as the main instrument for communicating plan participant rights and obligations under a benefit plan. ERISA plans are required to provide Summary Plan Descriptions to all plan participants. These documents must be provided every five years if changes have been made, otherwise every ten years. New hires should receive the SPD within 90 days of obtaining coverage. A common method of furnishing these documents is to use a wrap document which includes the necessary ERISA language and reference to coverage certificates.
Notices (New Hires and or Open Enrollment)
There are an assortment of notices that need to be distributed to plan participants. These Notices are a result of various employee benefit related laws that have been implemented over the years. These notices include, but are not limited to the following:
- COBRA-related notices
- Notice of Special Enrollment Rights
- Women’s Health and Cancer Rights Act
- HIPAA Privacy Notice
- Children’s Health Insurance Program Reauthorization Act (CHIPRA)
- Newborns and Mothers Health Protection Act
- Grandfathered Plan Status Notice
- Exchange Notice
- Medicare Part D Notice
The Form 5500 is an informational Annual Return/Report that applies to welfare benefit plans. The filing consists of the main form as well as specific schedules that relate to the Plan. The report lists information such as plan year, number of participants, plan funding, and insurance carriers or service providers. Form 5500 filings for welfare benefit plans are separate from Form 5500 requirements for 401(k) and pensions plans.
Most welfare benefit plans are required to file a form 5500 unless they meet an exemption allowed by the Department of Labor. Common exemptions include, but are not limited to:
- A welfare benefit plan that covers fewer than 100 participants as of the beginning of the plan year
- A governmental plan
- A church plan
Plan sponsors must also be mindful of whether their plan is “funded” or “unfunded” in determining if a Form 5500 needs to be filed. In basic terms, an unfunded plan pays claims and other expenses from the general assets of the employer. A funded plan uses a trust type of arrangement.
A plan sponsor that fails to file a Form 5500 potentially faces significant fines. Under applicable statutes, the penalty can be up to $1,100 per day, per plan. The Department of Labor offers a Delinquent Filer Voluntary Compliance Program (DFVCP) to encourage plan sponsors to submit late filings. The penalty under the DFVCP is typically capped at $4,000 per plan – relieving the plan sponsor of potential penalties for the late filings. A plan sponsor can file for multiple years, but the cap remains at $4,000 in total. A plan sponsor is only eligible to participate in the DFVCP if the Department of Labor has not already notified the plan sponsor of the failure to file the Form 5500.
Form 5500 obligations are another important reason to have a sound “wrap” document. A “wrap” document places all ERISA governed benefits under one plan. By having a “wrap” document, a plan sponsor is able to file one Form 5500 for all of their welfare benefit plans. This could be a significant factor when the DFVCP needs to be used. If the plan sponsor has not “wrapped” their plans, the $4,000 penalty would apply to each plan (medical, dental, life, etc.).
The Fedeli Group has extensive experience coordinating and navigating the DFVCP program for plan sponsors in coordination with our strategic partner accounting firms.
The Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) provides workers (and families) that lose their health benefits the right to continue their group health coverage for a limited time at their own expense. COBRA has very specific notice requirements and specific deadlines that need to be met.
A covered entity has additional regulatory responsibilities related to protecting protected health information (PHI). This responsibility is met by first appointing a Privacy Officer, who is then responsible for writing and implementing detailed policies and procedures to protect the PHI.
Affordable Care Act (ACA)
The ACA has brought an entire new set of requirements and enforcement activities to plan sponsors.
The law attempts to reshape and correct perceived problems related to offering a group health plan. Among the highlights of the law are expanded coverage for dependent children, removal of lifetime limits and pre-existing condition exclusions. The law also expanded overage for “preventive care” services. The law also features additional mandates for employers, referred to as “shared responsibility” requirements. This employer mandate requires employers to offer affordable coverage that meets minimum value requirements to employees working thirty or more hours per week. The law also brought about new filing requirements and taxes.
Fees, Taxes, and Filings
In addition to the Form 5500 filing requirement that was already on the books, the Affordable Care Act has added new filing and tax requirements intended to fund the ACA and stabilize insurance markets. These fees and taxes may apply to an employer based on their size and how they fund their benefit plans.
These requirements include:
- W2 reporting – If an employer sends 250 or more W2’s, they must include the value of a person’s benefits on the W2.
- Patient Centered Outcomes Research Institute (PCORI) Fee – This fee is intended fund the institute charged with investigating the effectiveness of various medical treatments.
- Transitional Reinsurance Program Fee – The purpose of this fee is to stabilize the premiums outside of the ACA marketplace.
- Forms 1094/1095 – These forms are intended to offer proof to the Federal Government in regards to employers and employees meeting the “Shared Responsibility” obligations under the ACA.
Regulatory Compliance Review is Critical to Benefit Plan Management
The Department of Labor has increased the frequency of health plan audits. Given the increased scrutiny and as a matter of good business practice, employers should review regulatory compliance on a periodic basis. The Fedeli Group will help you with this process. We will help you identify gaps and present and implement practical solutions.
Health and wellness is not simply the absence of disease and stress. It is an all encompassing state of physical, mental, emotional, spiritual and social well-being. Employers have the opportunity to provide a platform that promotes balance in the lives of their employees. Cultural driven design will significantly enhance wellness program success as evidenced through increased workplace engagement, increased productivity, and overall improvement in population health.
Culture Driven Design
Your organization has a unique culture and therefore should have a unique wellness program. We work with clients to develop and design wellness strategies that align with organizational goals, values, and mission. Careful consideration and discussion is given to demographics, geography, educational levels, and identified disease states.
Well-Being Drives Productivity
Healthier, more balanced employees are happier, more productive employees capable of improving day-to-day operations, enhancing customer satisfaction and contributing to organizational growth and achievement. Studies show most employers initially implement health and wellness programs to reduce health care costs, but over time realize value in other ways. We encourage clients to direct their focus beyond just potential health plan cost savings and towards factors such as increasing productivity, employee morale, lower employee turnover, a reduction in absenteeism, and increased engagement.
We are firm believers in preventive health. Chronic diseases and conditions such as heart disease, cancer, diabetes, obesity and arthritis, are among the most common, costly and often preventable health problems. According to the CDC, seven of the ten top causes of death in 2010 were chronic conditions, and 86% of all health care spending was for people with one or more chronic medical conditions. Disease management is important, but disease prevention is absolutely critical to the long-term control of health care costs. We urge clients to make preventive health a priority and believe that developing a personal relationship with a primary care physician is of utmost importance.
Stress is common, costly, often preventable, and generally overlooked. Unmanaged stress is damaging to an organization as it often leads to absenteeism, lower productivity, and turnover. We believe that stress management is a key component of one’s overall well-being. Providing tools and resources for stress management can be instrumental to health and well-being of employees and the overall success of an organization.
Improving health and well-being is a long-term process that requires reinforcement, commitment, and the changing of habits. Changing poor lifestyle habits is a personal decision that requires encouragement, education and resources. A wide range of resources are available to support, supplement, and facilitate wellness initiatives. We serve as your partner in the process of discovering and vetting resources that best suit your program.
We share our relationships and experience with professionals and experts across the field of corporate wellness. We are always exploring new approaches, tools, and services.
As part of your team, we work together to create a program and an environment that makes the healthier choice an easier choice.
Voluntary benefits allow individuals and families to manage the financial challenges that can develop from unpredictable events such as accidents, critical illness, disability, or death. A voluntary benefits program educates employees about these benefits and provides a means to accessing them in a convenient and informed way.
Most Americans do not have a personal relationship with an insurance agent or financial planner. As a result, accessing financial protection products can be a daunting and sometimes intimidating process. An employer sponsored program takes the fear out the purchase process while offering well vetted products that serve the interests of employees.
A successful implementation of a voluntary benefits program depends on developing an understanding of workplace demographics, geographic considerations, communication capabilities, and the underlying philosophy of the entire employee benefits program.
Voluntary benefit implementations can include the use of benefit counselors, online platforms, group meetings, or a combination of methods. Up-front planning is critical to initial and long-term success.
For employers, offering a voluntary benefits program can:
- Reduce absenteeism
- Improve understanding and appreciation of benefits by employees
- Provide “linkage” to other benefit coverages
For employees, voluntary benefits can provide:
- Access to high quality financial counselors
- Cost effective financial protection
- Avoidance of financial hardship
Most employers can benefit from a voluntary benefit plan offering. Because of our experience in voluntary benefits, we can help you develop an effective program that is beneficial to both you and your employees.
The Fedeli Group has substantial volume with leading health, disability, life, dental, and voluntary coverage insurers.
Through a discovery process we work with clients to identify requirements in the areas of plan design, administrative, and statutory compliance. Critical to the insurer selection process is a thorough understanding of contract provisions, financial ratings, claims payment reputation, and service standards.
Properly placed, an insurance company can be viewed as a valuable long-term partner. We often request that clients participate in finalist presentations. We find that this approach can further set expectations, drive accountability, and serve an important role in building relationships.